Audit 43749

East St. Louis School District 189 50-082-1890-22 SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ending June 30, 2022 SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2022 - 001 2. THIS FINDING IS: x New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: COVID-19 - Emergency Connectivity Fund Program 4. Project No.: 2022 5. AL No.: 32.009 6. Passed Through: N/A - Direct Award 7. Federal Agency: Federal Communication Commission 8. Criteria or specific requirement (including statutory, regulatory, or other citation) "According to 47 CFR Section 54.1706(c), ""Emergency Connectivity Fund support for eligible equipment and services is limited to no more than one fixed broadband internet access connection per location, and one connected device and one Wi-Fi hotspot per student, school staff member, or library patron. In addition there is also an ""unmet need"" requirement. According to the ""2022 Compliance Supplement,"" dated April 2022 and released by the Executive Office of the President Office of Management and Budget, ""When schools file for requests for reimbursement, however, they should only request reimbursement for eligible equipment and services provided to students or school staff who would otherwise lack broadband services and/or devices sufficient to engage in remote learning.""" 9. Condition15 Per review of the District's inventory listing containing devices purchased with the Emergency Connectivity Fund Program funding, 876 devices of the 6,000 devices purchased were not distributed to students. This indicates that amounts purchased and requested for reimbursement exceeded the "one device per student or staff member" requirement. The District was unable to provide supporting documentation for the 876 devices to support compliance with the "Special Tests, Restricted Purposes" compliance requirement that states there must be an "unmet need" and that there are "per-user limitations." 10. Questioned Costs16 Questioned costs for assistance listing number 32.009 totaled $324,926. This amount was computed by multiplying the 876 undistributed devices by the cost of each device ($370.92). 11. Context17 Questioned costs were determined by reviewing the inventory listing for all devices funded with the Emergency Connectivity Fund Program. Out of the 6000 devices purchased, 876 were not assigned to a specific student or school staff member. 12. Effect The District purchased extra devices that exceeded the number of students or school staff who lacked current broadband services and/or devices sufficient to engage in remote learning. 13. Cause Lack of authoritative guidance and resources specific to the Emergency Connectivity Funding which was a new federal grant. The District interpreted the guidance provided that they could order additional devices needed to address historically high mobility rate and high rate of damaged, lost or stolen chromebooks unique to their District as a result of economic challenges including a very high proportion of low income students. 14. Recommendation We recommend that the District implement procedures such as additional trainings and correspondence with the federal agency to ensure the grants requirements are being met. 15. Management's response18 See corrective action plan 14 See footnote 11. 15 Include facts that support the deficiency identified on the audit finding (?200.516 (b)(3)). 16 Identify questioned costs as required by ?200.516 (a)(3 - 4). 17 See footnote 12. 18 To the extent practical, indicate when management does not agree with the finding, questioned cost, or both.

East St. Louis School District 189 50-082-1890-22 SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ending June 30, 2022 SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2022 - 001 2. THIS FINDING IS: x New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: COVID-19 - Emergency Connectivity Fund Program 4. Project No.: 2022 5. AL No.: 32.009 6. Passed Through: N/A - Direct Award 7. Federal Agency: Federal Communication Commission 8. Criteria or specific requirement (including statutory, regulatory, or other citation) "According to 47 CFR Section 54.1706(c), ""Emergency Connectivity Fund support for eligible equipment and services is limited to no more than one fixed broadband internet access connection per location, and one connected device and one Wi-Fi hotspot per student, school staff member, or library patron. In addition there is also an ""unmet need"" requirement. According to the ""2022 Compliance Supplement,"" dated April 2022 and released by the Executive Office of the President Office of Management and Budget, ""When schools file for requests for reimbursement, however, they should only request reimbursement for eligible equipment and services provided to students or school staff who would otherwise lack broadband services and/or devices sufficient to engage in remote learning.""" 9. Condition15 Per review of the District's inventory listing containing devices purchased with the Emergency Connectivity Fund Program funding, 876 devices of the 6,000 devices purchased were not distributed to students. This indicates that amounts purchased and requested for reimbursement exceeded the "one device per student or staff member" requirement. The District was unable to provide supporting documentation for the 876 devices to support compliance with the "Special Tests, Restricted Purposes" compliance requirement that states there must be an "unmet need" and that there are "per-user limitations." 10. Questioned Costs16 Questioned costs for assistance listing number 32.009 totaled $324,926. This amount was computed by multiplying the 876 undistributed devices by the cost of each device ($370.92). 11. Context17 Questioned costs were determined by reviewing the inventory listing for all devices funded with the Emergency Connectivity Fund Program. Out of the 6000 devices purchased, 876 were not assigned to a specific student or school staff member. 12. Effect The District purchased extra devices that exceeded the number of students or school staff who lacked current broadband services and/or devices sufficient to engage in remote learning. 13. Cause Lack of authoritative guidance and resources specific to the Emergency Connectivity Funding which was a new federal grant. The District interpreted the guidance provided that they could order additional devices needed to address historically high mobility rate and high rate of damaged, lost or stolen chromebooks unique to their District as a result of economic challenges including a very high proportion of low income students. 14. Recommendation We recommend that the District implement procedures such as additional trainings and correspondence with the federal agency to ensure the grants requirements are being met. 15. Management's response18 See corrective action plan 14 See footnote 11. 15 Include facts that support the deficiency identified on the audit finding (?200.516 (b)(3)). 16 Identify questioned costs as required by ?200.516 (a)(3 - 4). 17 See footnote 12. 18 To the extent practical, indicate when management does not agree with the finding, questioned cost, or both.